NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: nht70-1.17OpenDATE: 03/17/70 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: The Auto Sun Products Company TITLE: FMVSS INTERPRETATION TEXT: Your letter of February 13 indicates that your understanding of the regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts. Before you act on your understanding, however, you should give special consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them. Sincerely, |
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ID: nht70-1.18OpenDATE: 04/01/70 EST. FROM: Lawrence R. Schneider; NHTSA TO: Motion Development TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of June 23 requesting confirmation that vehicles with a curb weight of 1,000 pounds or less are not required to meet Federal motor vehicle safety standards. As Mr. Vinson of my staff informed you, 49 CFR @@571.7(a) requires conformance to Federal standards of "motorcycles and trailers regardless of weight and...all other motor vehicles over 1,000 pounds curb weight." Thus your dune buggy with a "weight" of 385 pounds appears to be exempt from the Federal standards. |
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ID: nht70-1.19OpenDATE: 07/01/70 EST FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Department of California Highway Patrol TITLE: FMVSR INTERPRETATION TEXT: In response to your letter of July 9 to Mr. Toms I would like to make clear that the creation of the subcategory "mobile structure trailer" does not remove mobile homes towed on their own wheels from their original categorization under the Federal motor vehicle safety standards as trailers. This means that rule making actions applicable to "trailers" are also applicable to mobile homes unless there is specific language indicating that a Federal standard or portion thereof does not apply to a mobile structure trailer. Therefore, in answer to your specific questions: (a) Proposed Standards Nos. 119 and 120 would apply to trailers and therefore to mobile structure trailers. (b) No proposal has been issued which would extend the Federal hydraulic brake standard, No. 105, to cover trailers. Therefore a State may adopt hydraulic brake requirements for mobile homes. However, we have issued a proposal (Docket No. 70-16; 35 F.R. 10456, June 26, 1970) which would establish requirements for "trailers equipped with air brake systems". If adopted, this new standard would preclude a state from adopting other than identical air brake requirements for mobile homes and other trailers. The point may be academic as it is my understanding that mobile homes, as a rule, are equipped with electric brakes. |
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ID: nht70-1.2OpenDATE: 10/06/70 FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA TO: European Tyre and Rim Technical Organization TITLE: FMVSS INTERPRETATION TEXT: (Illegible Text) |
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ID: nht70-1.20OpenDATE: 09/14/70 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Mobile Homes Manufacturers Association TITLE: FMVSR INTERPRETATION |
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ID: nht70-1.21OpenDATE: 06/03/70 FROM: Rodolfo A. Diaz; signature by George Nield -- NHTSA TO: Export Vehicle Engineering Dept. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 20 in which you ask "whether the Station Wagon should be construed as a Passenger Car or a Multipurpose Passenger Vehicle". You are correct in your interpretation that a station wagon "does not normally fall under" the category of multipurpose passenger vehicle. However, if a station wagon "is constructed on a truck chassis" or "with special features for occasional off-road operation", such as four-wheel drive, it would be considered a multipurpose passenger vehicle. I hope this clarifies the matter for you. |
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ID: nht70-1.22OpenDATE: 10/27/70 FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA TO: General Motors Technical Center TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter to Mr. Toms of October 15, 1970, in which you asked whether General Motors could provide one consumer information document to fleet purchasers of motor vehicles, rather than putting a booklet in each car as is done in the usual case. The answer is yes. 49 CFR 575.6(a) requires that the information be provided "to that purchaser", "at the time a motor vehicle is delivered" to him. It does not require that the information be in the vehicle, or that there be one booklet per vehicle. We are pleased to be of assistance. |
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ID: nht70-1.23OpenDATE: 03/04/70 FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA TO: Trelleborg Rubber Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of February 4, 1970, to the National Highway Safety Bureau concerning the labeling requirements for motor vehicle tires manufactured prior to August 1, 1968. Federal Motor Vehicle Safety Standard No. 109 requires that all motor vehicle passenger car tires manufactured after January 1, 1968, conform to the requirements as cited. I have enclosed a copy of Standard No. 109 and No. 110 with amendments for your reference. Section 54.3 specifies the labeling requirements. You will note 54.3.1 permits the sale of tires manufactured during the period January 1, 1968, to August 1, 1968, which have a label or tag affixed that incorporates the specified information. Inclusion of information on the invoice does not relieve the manufacturer from affiding the proper labeling on each tire. |
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ID: nht70-1.24OpenDATE: 04/17/70 FROM: Lawrence R. Schneider; NHTSA TO: Hans J. Loeffler TITLE: FMVSR INTERPRETATION TEXT: This is in response to our letter of April 5 and confirms your understanding that any Porsche automobile manufactured prior to January 1, 1968, need not confirm to Federal motor vehicle safety standards in order to be admitted into the United States. If you wish to import a vehicle manufactured prior to that date, you may be asked to execute Form Ne-7 (Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Standards) at the port of entry. You should supply the vehicle data requested and check box 1, the declaration that "The merchandise was manufactured on a date when there was no Federal motor vehicle safety standard in effect which was applicable to it". I enclose a copy of this Form for your information. |
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ID: nht70-1.25OpenDATE: 06/20/70 FROM: Lawrence R. Schneider; NHTSA TO: Massachusetts Institute of Technology TITLE: FMVSR INTERPRETATION TEXT: I have read with great interest your letter of June 10 and its enclosures. You appear to be seeking an assurance that "we, the C&CR Organization Committee, are complying with all Federal rules and regulations in regard to highway safety", and information ensuring "that the race vehicles involved are satisfactory to [National Highway Safety Bureau] specifications and regulations". The first part of your inquiry really requires a response from us to [Illegible Words] of your entry rules, which states that the entrant shall "Satisfy any additional requirements imposed by the U.S. Federal Government since cross-country travel will take place on interstate highways". There are no conditions which must be met prior to operation of experimental vehicles on the interstate system. Nor are there any Federal requirements applicable to the Committee as promoter or sponsor of a competition conducted in part on the interstate system. State and local laws, if any, would have to be followed of course. In response to the second part of your inquiry the Federal "specifications and regulations" concerned are the Federal Motor Vehicle Safety Standards, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966. The Committee has no responsibility under the Act for ensuring compliance with the Federal safety standards. This responsibility rests with the vehicle's original manufacturer, and with any person modifying a vehicle prior to its first sale in a manner affecting compliance with the safety standards. It is evident that standard production motor vehicles (such as the Chevelles presented to the Committee by General Motors) which originally [Page 2 Is Missing.] |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.